A lesser penalty nonrenewal of certification can also be imposed by the state when the individual seeking recertification fails to satisfy the requirements for recertification. In the past such requirements have usually been related to professional Growth (e.g. completion of a specified number of credits during a certain period of time). More recently a few states have imposed a test requirement as a precondition for recertification. The courts have upheld requirements for recertification if they are shown to be reasonably related to maintenance of standards or improved performance. If the requirement is found not to be reasonably related certification will be upheld